| Categories of Personal Data | Diagnostic logs (Vehicle Identification Number (VIN), hardware and software versions, data streams, flashing processes, etc.); vehicle operation and diagnostic data (such as mileage, vehicle status, fault codes, and sensor data). |
| Purpose | Use offline diagnostic tools to diagnose vehicle faults. Such data can also be used for quality traceability, product safety analysis, and related dispute resolution when necessary. |
| Legal Basis |
Contract: Provision of vehicle warranty and diagnostic services.
Legitimate interests: Risk prevention and safety, compliance and traceability requirements. |
| Retention | For the purposes of fault diagnosis, warranty handling, and quality traceability, we will retain offline diagnostic logs and related vehicle data for as long as necessary to fulfill the above purposes. Where necessary for handling warranty disputes, product safety incidents, defect investigations, or to comply with applicable statutory limitation periods or liability traceability requirements, such data may be retained for the relevant legal retention period. Upon expiry of the applicable retention period, the data will be deleted or anonymized. |
| Categories of Personal Data | Username, user ID, phone number, email address, feedback description, etc. |
| Purpose | Account management, identity verification, and contact details for security notifications; customer service, issue tracking, and improving product experience, etc. |
| Legal Basis |
Contract: Account identification, identity verification, and provision of account services.
Legitimate interests: Security and abuse prevention/anti-fraud; customer service follow-up, issue tracking, and limited service improvements based on the existing service relationship. |
| Retention | During the lifetime of the user account/retained for 90 days after account deletion. |
| Categories of Personal Data |
Vehicle identification information: VIN, chassis number; real-time and historical vehicle data: T-box* status, location information; alarm records; OTA* update information.
*T-box (Telematics Box): an in-vehicle device that connects the car to the network and sends/receives data. *OTA (Over-the-Air): updating the vehicle’s software remotely via the internet. |
| Purpose | Vehicle unique identification, vehicle management, remote monitoring, status updates, risk control, system security, software updates. |
| Legal Basis |
Contract: To provide the core connected vehicle functions necessary for fulfilling the user agreement (e.g., vehicle status display, remote services, vehicle locating, vehicle binding, and related account services).
Legitimate interests: Vehicle and system security, anomaly detection, anti-fraud measures, accident/fault investigation, necessary software security updates, and cybersecurity protection. Consent: For location-based features that are not essential for providing core services but activated by the user (e.g., continuous location sharing, geo-fencing), we will obtain your consent where applicable; you may disable these features or withdraw your consent at any time within the App. |
| Retention |
Real-time vehicle location and status data: We retain records of your vehicle’s real-time location and status data (such as engine, controller, battery information, etc.) for 90 days, continuously updated on a rolling basis.
Vehicle account binding information: While your vehicle is linked to your account, we store basic vehicle information, such as the Vehicle Identification Number (VIN) and model. If you unlink, delete your account, or the service ends, we will stop associating this information with your account. Limited vehicle identification information may still be retained as necessary for vehicle lifecycle management (e.g., recalls, quality tracking) until the vehicle is decommissioned or the system’s maximum silent period is reached (e.g., 10 consecutive years without a network connection). Onboard devices, remote operations, and system logs: We retain information about connected onboard devices (e.g., device ID, status logs), remote operation records (user actions and control commands), and system logs (operation records, task execution records) for 90 days to ensure proper service operation, troubleshoot issues, and maintain system security. Geo-fencing features: If geo-fencing is enabled, related data (location alerts, user-defined rules) are retained for 90 days while the feature is active. If disabled, the data is generally retained for an additional 90 days for historical queries or troubleshooting and will then be automatically deleted. Software update records: During the period your account is linked to the vehicle, we retain records related to software updates (e.g., VIN, T-box, OTA). After unlinking, account deletion, or service termination, these records may continue to be retained for up to 5 years for warranty, quality issue handling, dispute resolution, or product safety tracking. Location-based features: Data related to continuous location tracking or geo-fencing is only processed when the corresponding feature is enabled and is retained according to the applicable retention period for each feature. |
| Categories of Personal Data | Name, phone number, VIN |
| Purpose | For warranty management, recalls, and compliance reporting. |
| Legal Basis |
Contract: Warranty and after-sales service delivery.
Legitimate interests: Vehicle life-cycle management (traceability of VIN and owners, coordination of after-sales services, quality monitoring, and defect investigation); ensuring consistency of service standards within the dealer network, preventing duplicate or erroneous registrations, and properly handling customer complaints related to the source vehicle and after-sales services. Legal Obligation: Recalls, regulatory reporting, and other statutory obligations. |
| Retention | We will retain the relevant data for the duration of the vehicle’s use and after-sales service management; if necessary for recalls, product safety, quality defect investigations, dispute resolution, or as required by applicable laws, the data may be retained for the corresponding statutory retention period, liability traceability period, or limitation period. After such periods expire, the data will be deleted or anonymized. |
| Categories of Personal Data |
Fault description: text, photos, videos/audio.
*Note: Please provide only materials directly related to the fault, repair, or claim, and avoid uploading unrelated faces, ID documents, health information, or other third-party data. |
| Purpose | Used to document the repair process and provide evidence for claims. |
| Legal Basis | Legitimate interests: Claims and warranty responsibility assessment, prevention of fraudulent or duplicate claims. |
| Retention | We will retain the relevant materials during the period necessary for claim review, warranty responsibility assessment, dispute resolution, and any required audits. If the materials inadvertently contain sensitive content unrelated to the claim, we will, to the extent feasible, promptly delete, redact, or restrict access to such content. |
| Categories of Personal Data | Invoice（For example, name, address, amount, date, and, where applicable, tax/payment information necessary to complete the settlement.） |
| Purpose | As proof for settlement. |
| Legal Basis |
Contract: Fulfillment of vehicle warranty or service agreements.
Legal Obligation: Financial, tax, and accounting compliance. |
| Retention | We will retain the relevant data for the period necessary to complete claim settlement and fulfill related financial, tax, accounting, and audit obligations; generally, the retention will follow applicable legal requirements, and where necessary, data may be kept until the expiration of the corresponding statutory period (for example, up to 10 years, depending on applicable law). |
| Categories of Personal Data | Name, feedback content, email, etc. |
| Purpose | After-sales service feedback and satisfaction survey. |
| Legal Basis | Legitimate interests：To evaluate and improve after-sales service quality, monitor dealer performance, and fulfill customer care and dispute prevention responsibilities. |
| Retention | Original follow-up records, questionnaires, or feedback materials are generally retained for one year and deleted afterward. If used only for statistical analysis, we will retain them in aggregated or de-identified form whenever possible. If call recordings are introduced in the future, a separate, shorter retention period will apply. |